Abdul Majeed
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IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
Crl. Misc. No._____________H/2001 Abdul Majeed S/o Muhammad Yar, caste Jhabeel, R/o Bahawalpur Ghalwan, Tehsil Ahmad Pur East, District Bahawalpur. Petitioner VERSUS 1. Kareem Bakhsh
Sons of Nabi Bakhsh,
2. Azeem Bakhsh
caste Drig, R/o Basti Nachang,
3. Yaseen
Mouza Bait Kech, Tehsil Jalalpur
4.
Raheem Bakhsh
Pirwala, District Multan. Respondents
Petition U/s 491 Cr.P.C. for the recovery of Mst. Amna Mai d/o Bashir Ahmad aged 19 years presently detained illegally and unlawfully by the respondents.
Respectfully Sheweth: 1. That the names and addresses of the parties have correctly been given for the purpose of their summons and citations. 2. That the petitioner was living with Bashir Ahmad, the father of detenue (Mst. Amna Mai) and there were cordial relations between the petitioner and the family of Bashir Ahmad. After sometime, it was developed in the mind of Bashir Ahmad to marry her daughter Mst. Amna Mai to the petitioner. On this pretext, the said Bashir Ahmad received a sum of Rs. 50,000/and it was also promised that a piece of land measuring 4 Kanals would be transferred in the name of his son Sabir Hussain.
3. That when this matter came to the knowledge of the respondents (the in-laws of Bashir Ahmed) they started to pressurise the father of Mst. Amna Mai, not to marry the detenue (Mst. Amna Mai) with the petitioner. Bashir Ahmad the father of Mst. Amna Mai, directed his wife Mst. Lal Mai to ceremonise the marriage some where else instead of their native town. In this connection the Nikah of Mst. Amna Mai with the implied consent of her father, in the presence of her mother was performed on 4.3.2000, in the compound of District Courts Lodhran. The copy of Nikahnama is Annex “A”. 4. That after performance of Nikah, the petitioner started her matrimonial life; and once again the petitioner was invited to live as “Ghar Damad”. This offer was accepted by the petitioner and the petitioner, along-with his wife shifted to the house of his father-in-law. This relation between the petitioner and his in laws, again infuriated the respondents. They invited the wife of petitioner to visit their home on 8.6.2001, and since then she is in the illegal and unlawful custody of the respondents. 5. That the petitioner visited the house of the respondents time to time during this period, but was not allowed and permitted to see Mst. Amna Mai. The respondents are pressurising Mst. Amna Mai and the petitioner as well for the execution of divorce, for which neither the petitioner nor Mst. Amna Mai is ready to fulfill the desire of the respondents. 6. That the petitioner is under the apprehension that if the detenue Mst. Amna Mai is not released from the clutches of the respondents, Mst. Amna Mai might be murdered or another “Nikah” will be performed with some other person against her free will and consent. 7. That the petitioner being the husband of the detenue Mst. Amna Mai, has every right for her custody to pass smooth matrimonial life and the respondents are not entitled for the custody of the detenue Mst. Amna Mai by any means.
Keeping in view the above-mentioned facts, it is respectfully prayed that Mst. Amna Mai the detenue may please be ordered to be recovered from the respondents by declaring their custody illegal and unlawful. It is further prayed that the detenue may please be set at liberty to associate with the petitioner for passing her matrimonial life. Any other order, direction or relief which this Hon’ble Court deems fit, may please be extended in the favour of petitioner to meet the ends of justice. Humble Petitioner, Dated: ___________
Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959
Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176
CERTIFICATE: Certified as per instructions of the client, that this is the first petition on the subject matter. No such petition has earlier been filed before this Hon’ble Court. Advocate
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
Crl. Misc. No._____________H/2001 Abdul Majeed
Vs.
Kareem Bakhsh etc.
AFFIDAVIT of: Abdul Majeed S/o Muhammad Yar, caste Jhabeel, R/o Bahawalpur Ghalwan, Tehsil Ahmad Pur East, District Bahawalpur. I, the above named deponent do hereby solemnly affirm and declare as under: 1. That the names and addresses of the parties have correctly been given for the purpose of their summons and citations. 2. That the petitioner was living with Bashir Ahmad, the father of detenue (Mst. Amna Mai) and there were cordial relations between the petitioner and the family of Bashir Ahmad. After sometime, it was developed in the mind of Bashir Ahmad to marry her daughter Mst. Amna Mai to the petitioner. On this pretext, the said Bashir Ahmad received a sum of Rs. 50,000/and it was also promised that a piece of land measuring 4 Kanals would be transferred in the name of his son Sabir Hussain. 3. That when this matter came to the knowledge of the respondents (the in-laws of Bashir Ahmed) they started to pressurise the father of Mst. Amna Mai, not to marry the detenue (Mst. Amna Mai) with the petitioner. Bashir Ahmad the father of Mst. Amna Mai, directed his wife Mst. Lal Mai to ceremonise the marriage some where else instead of their native town. In this connection the Nikah of Mst. Amna Mai with the implied consent of her father, in the presence of her mother was performed on 4.3.2000, in the compound of District Courts Lodhran. The copy of Nikahnama is Annex “A”.
4. That after performance of Nikah, the petitioner started her matrimonial life; and once again the petitioner was invited to live as “Ghar Damad”. This offer was accepted by the petitioner and the petitioner, along-with his wife shifted to the house of his father-in-law. This relation between the petitioner and his in laws, again infuriated the respondents. They invited the wife of petitioner to visit their home on 8.6.2001, and since then she is in the illegal and unlawful custody of the respondents. 5. That the petitioner visited the house of the respondents time to time during this period, but was not allowed and permitted to see Mst. Amna Mai. The respondents are pressurising Mst. Amna Mai and the petitioner as well for the execution of divorce, for which neither the petitioner nor Mst. Amna Mai is ready to fulfill the desire of the respondents. 6. That the petitioner is under the apprehension that if the detenue Mst. Amna Mai is not released from the clutches of the respondents, Mst. Amna Mai might be murdered or another “Nikah” will be performed with some other person against her free will and consent. 7. That the petitioner being the husband of the detenue Mst. Amna Mai, has every right for her custody to pass smooth matrimonial life and the respondents are not entitled for the custody of the detenue Mst. Amna Mai by any means. 8. That the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
In re: C.M. No. _____________/2001 In Crl. Misc. No._____________H/2001 Abdul Majeed
Vs.
Kareem Bakhsh etc.
APPLICATION FOR DISPENSING WITH THE FILING OF CERTIFIED COPY OF ANNEXURE. =========================================
Respectfully Sheweth:That certified copy of Annexure “A” is not available. However, uncertified/photo state copy of the same has been annexed with the petition, which is the true copy of the original document. It is, therefore, respectfully prayed that this Hon’ble court may please dispense with the filing of aforesaid copy of the document. APPLICANT Dated: __________
Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959
Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
In re: C.M. No. _____________/2001
In Crl. Misc. No._____________H/2001 Abdul Majeed
Vs.
Kareem Bakhsh etc.
DISPENSATION APPLICATION. AFFIDAVIT of: Abdul Majeed S/o Muhammad Yar, caste Jhabeel, R/o Bahawalpur Ghalwan, Tehsil Ahmad Pur East, District Bahawalpur.
I, the above named deponent do hereby solemnly affirm and declare that the contents of the above-mentioned application are true and correct to the best of my knowledge and belief and nothing has been kept concealed thereto. DEPONENT
Verification: Verified on oath at Multan, this _____ day of June 2001 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
Crl. Misc. No._____________H/2001 Abdul Majeed
Vs.
Kareem Bakhsh etc.
INDEX S. No. NAME OF DOCUMENTS 1
Urgent Form
2
Petition U/s 491 Cr.P.C.
3
Affidavit
4
Copy of Nikahnama.
5
Dispensation Application.
6
Affidavit.
7
Vakalatnama
ANNEXES PAGES
A
PETITIONER Dated: ____________
Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959
Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176
Crl. Misc. No._____________H/2001 Abdul Majeed S/o Muhammad Yar, caste Jhabeel, R/o Bahawalpur Ghalwan, Tehsil Ahmad Pur East, District Bahawalpur. Petitioner VERSUS 1. Kareem Bakhsh
Sons of Nabi Bakhsh,
2. Azeem Bakhsh
caste Drig, R/o Basti Nachang,
3. Yaseen
Mouza Bait Kech, Tehsil Jalalpur
4.
Raheem Bakhsh
Pirwala, District Multan. Respondents
Petition U/s 491 Cr.P.C. for the recovery of Mst. Amna Mai d/o Bashir Ahmad aged 19 years presently detained illegally and unlawfully by the respondents.
Respectfully Sheweth: 1. That the names and addresses of the parties have correctly been given for the purpose of their summons and citations. 2. That the petitioner was living with Bashir Ahmad, the father of detenue (Mst. Amna Mai) and there were cordial relations between the petitioner and the family of Bashir Ahmad. After sometime, it was developed in the mind of Bashir Ahmad to marry her daughter Mst. Amna Mai to the petitioner. On this pretext, the said Bashir Ahmad received a sum of Rs. 50,000/and it was also promised that a piece of land measuring 4 Kanals would be transferred in the name of his son Sabir Hussain.
3. That when this matter came to the knowledge of the respondents (the in-laws of Bashir Ahmed) they started to pressurise the father of Mst. Amna Mai, not to marry the detenue (Mst. Amna Mai) with the petitioner. Bashir Ahmad the father of Mst. Amna Mai, directed his wife Mst. Lal Mai to ceremonise the marriage some where else instead of their native town. In this connection the Nikah of Mst. Amna Mai with the implied consent of her father, in the presence of her mother was performed on 4.3.2000, in the compound of District Courts Lodhran. The copy of Nikahnama is Annex “A”. 4. That after performance of Nikah, the petitioner started her matrimonial life; and once again the petitioner was invited to live as “Ghar Damad”. This offer was accepted by the petitioner and the petitioner, along-with his wife shifted to the house of his father-in-law. This relation between the petitioner and his in laws, again infuriated the respondents. They invited the wife of petitioner to visit their home on 8.6.2001, and since then she is in the illegal and unlawful custody of the respondents. 5. That the petitioner visited the house of the respondents time to time during this period, but was not allowed and permitted to see Mst. Amna Mai. The respondents are pressurising Mst. Amna Mai and the petitioner as well for the execution of divorce, for which neither the petitioner nor Mst. Amna Mai is ready to fulfill the desire of the respondents. 6. That the petitioner is under the apprehension that if the detenue Mst. Amna Mai is not released from the clutches of the respondents, Mst. Amna Mai might be murdered or another “Nikah” will be performed with some other person against her free will and consent. 7. That the petitioner being the husband of the detenue Mst. Amna Mai, has every right for her custody to pass smooth matrimonial life and the respondents are not entitled for the custody of the detenue Mst. Amna Mai by any means.
Keeping in view the above-mentioned facts, it is respectfully prayed that Mst. Amna Mai the detenue may please be ordered to be recovered from the respondents by declaring their custody illegal and unlawful. It is further prayed that the detenue may please be set at liberty to associate with the petitioner for passing her matrimonial life. Any other order, direction or relief which this Hon’ble Court deems fit, may please be extended in the favour of petitioner to meet the ends of justice. Humble Petitioner, Dated: ___________
Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959
Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176
CERTIFICATE: Certified as per instructions of the client, that this is the first petition on the subject matter. No such petition has earlier been filed before this Hon’ble Court. Advocate
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
Crl. Misc. No._____________H/2001 Abdul Majeed
Vs.
Kareem Bakhsh etc.
AFFIDAVIT of: Abdul Majeed S/o Muhammad Yar, caste Jhabeel, R/o Bahawalpur Ghalwan, Tehsil Ahmad Pur East, District Bahawalpur. I, the above named deponent do hereby solemnly affirm and declare as under: 1. That the names and addresses of the parties have correctly been given for the purpose of their summons and citations. 2. That the petitioner was living with Bashir Ahmad, the father of detenue (Mst. Amna Mai) and there were cordial relations between the petitioner and the family of Bashir Ahmad. After sometime, it was developed in the mind of Bashir Ahmad to marry her daughter Mst. Amna Mai to the petitioner. On this pretext, the said Bashir Ahmad received a sum of Rs. 50,000/and it was also promised that a piece of land measuring 4 Kanals would be transferred in the name of his son Sabir Hussain. 3. That when this matter came to the knowledge of the respondents (the in-laws of Bashir Ahmed) they started to pressurise the father of Mst. Amna Mai, not to marry the detenue (Mst. Amna Mai) with the petitioner. Bashir Ahmad the father of Mst. Amna Mai, directed his wife Mst. Lal Mai to ceremonise the marriage some where else instead of their native town. In this connection the Nikah of Mst. Amna Mai with the implied consent of her father, in the presence of her mother was performed on 4.3.2000, in the compound of District Courts Lodhran. The copy of Nikahnama is Annex “A”.
4. That after performance of Nikah, the petitioner started her matrimonial life; and once again the petitioner was invited to live as “Ghar Damad”. This offer was accepted by the petitioner and the petitioner, along-with his wife shifted to the house of his father-in-law. This relation between the petitioner and his in laws, again infuriated the respondents. They invited the wife of petitioner to visit their home on 8.6.2001, and since then she is in the illegal and unlawful custody of the respondents. 5. That the petitioner visited the house of the respondents time to time during this period, but was not allowed and permitted to see Mst. Amna Mai. The respondents are pressurising Mst. Amna Mai and the petitioner as well for the execution of divorce, for which neither the petitioner nor Mst. Amna Mai is ready to fulfill the desire of the respondents. 6. That the petitioner is under the apprehension that if the detenue Mst. Amna Mai is not released from the clutches of the respondents, Mst. Amna Mai might be murdered or another “Nikah” will be performed with some other person against her free will and consent. 7. That the petitioner being the husband of the detenue Mst. Amna Mai, has every right for her custody to pass smooth matrimonial life and the respondents are not entitled for the custody of the detenue Mst. Amna Mai by any means. 8. That the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
In re: C.M. No. _____________/2001 In Crl. Misc. No._____________H/2001 Abdul Majeed
Vs.
Kareem Bakhsh etc.
APPLICATION FOR DISPENSING WITH THE FILING OF CERTIFIED COPY OF ANNEXURE. =========================================
Respectfully Sheweth:That certified copy of Annexure “A” is not available. However, uncertified/photo state copy of the same has been annexed with the petition, which is the true copy of the original document. It is, therefore, respectfully prayed that this Hon’ble court may please dispense with the filing of aforesaid copy of the document. APPLICANT Dated: __________
Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959
Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
In re: C.M. No. _____________/2001
In Crl. Misc. No._____________H/2001 Abdul Majeed
Vs.
Kareem Bakhsh etc.
DISPENSATION APPLICATION. AFFIDAVIT of: Abdul Majeed S/o Muhammad Yar, caste Jhabeel, R/o Bahawalpur Ghalwan, Tehsil Ahmad Pur East, District Bahawalpur.
I, the above named deponent do hereby solemnly affirm and declare that the contents of the above-mentioned application are true and correct to the best of my knowledge and belief and nothing has been kept concealed thereto. DEPONENT
Verification: Verified on oath at Multan, this _____ day of June 2001 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
Crl. Misc. No._____________H/2001 Abdul Majeed
Vs.
Kareem Bakhsh etc.
INDEX S. No. NAME OF DOCUMENTS 1
Urgent Form
2
Petition U/s 491 Cr.P.C.
3
Affidavit
4
Copy of Nikahnama.
5
Dispensation Application.
6
Affidavit.
7
Vakalatnama
ANNEXES PAGES
A
PETITIONER Dated: ____________
Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959
Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176
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